"ADVISORY OPINION 21-04—HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT
(1) PERMISSIBLE ANNUAL PENALTIES, (2) REQUIREMENT THAT PENALTIES BE PROPORTIATE, REASONABLE, AND CONSISTENT,
(3) FAILURE TO COOPERATE AS A SEPARATE VIOLATION, AND (4) MEANING OF “FINANCIAL INSTITUTION”
"
Guidance regarding HHS General Counsel’s views on certain pertinent HIPAA matters, in light of the Fifth Circuit’s recent M.D. Anderson decision.
Final
Issued by: Office of the General Counsel (OGC)
Issue Date: January 19, 2021
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